This document does not identify any vendor, reproduce internal communications, or disclose proprietary materials.
This is not a legal filing.
This is a structured account of a Data Subject Access Request (DSAR) process examined through a governance lens.
All statements reflect documented sequence and observable procedural behavior.
$ request.type Data Subject Access Request (DSAR)Statutory Basis
The request was submitted under:
- GDPR Article 12 (transparent communication and response timing)
- GDPR Article 15 (right of access)
- GDPR Article 17 (right to erasure)
Article 12(3) establishes a one-month response period, unless a lawful extension is communicated within that timeframe.
$ governing_law GDPR Article 12(3)Initial Submission
A Data Subject Access Request was formally submitted.
- Invoked Articles 12 and 15.
- Reiterated a request for erasure under Article 17.
- Requested confirmation of receipt and processing in accordance with Article 12(3).
- Receipt was acknowledged.
The statutory response period commenced.
$ continuity.checkFollow-Up
After the statutory period elapsed without:
- Confirmation of processing,
- A lawful extension notice, or
- A substantive response,
A second written follow-up was issued requesting:
- Confirmation the request was being processed,
- The reason for delay,
- An expected completion date.
No substantive response was received at that stage.
merge followup.notice --strategy=state_assertionFinal Notice
At Day 46, a written Final Notice was issued stating:
- The request had exceeded the one-month statutory response window.
- No valid extension had been communicated.
- Full access remained requested under Article 15.
- Erasure remained requested under Article 17.
This notice documented the elapsed statutory period and reiterated compliance obligations under GDPR.
checkout final.notice --mode=deadline_enforcedObserved Process Characteristics
This resulted in observable discontinuity between:
- The acknowledged statutory request, and
- The ticket reference used in subsequent communications.
- The procedural effect was fragmentation of obligation-state tracking.
No inference is made regarding intent.
This observation concerns internal process continuity only.
Regulatory Action
Following expiration of the statutory response window, a regulatory complaint was filed.
This document does not evaluate regulatory outcome.
It evaluates governance behavior prior to resolution.
Resolution
Approximately two weeks after issuance of the Final Notice, the matter concluded.
Due to structural complexity within portions of the request, I independently determined that it was in the mutual interest of both parties to complete aspects of the reconciliation process directly.
The original request was closed.
This determination was unilateral and procedural in nature.
Governance Analysis
This case illustrates the distinction between:
- Eventual closure
- continuity-preserved compliance
and
Three observable characteristics emerged:
The statutory timer elapsed without extension notice.Ticket references did not consistently align with the acknowledged request.
Resolution required stabilization outside the original intake pathway.
The issue is not outcome.
The issue is whether obligation-state was preserved from initiation to completion without fragmentation.
A statutory deadline functions as a continuity test.
When obligation must be reintroduced after expiration, governance maturity is measured not by final closure, but by how continuity behaved under deadline.
git add . && git commit -m "statutory window elapsed | record updated"Closing
This case does not evaluate individuals. It evaluates process design under time-bound statutory obligation.
The matter concluded.
The governance question remains: Was the obligation continuously tracked — or reconstructed after lapse?